①The provisions of the Corporation Tax Act as amended by the provisions of Article 2 (limited to the amending provisions set forth in Article 1, item (vii), (b) of the Supplementary Provisions) apply to a trust that takes effect on or after the Effective Date of the Trust Act (for a trust created by will, limited to one for which the will was made on or after the Effective Date of the Trust Act, and including a new-law trust), and with regard to a trust that took effect before the Effective Date of the Trust Act (for a trust created by will, including one for which the will was made before the Effective Date of the Trust Act, and excluding a new-law trust and a trust that has received the authorization for transition prescribed in Article 4, paragraph (1) of the Supplementary Provisions of the Act on Public Interest Trusts (Act No. 30 of 2024)), the provisions then in force continue to govern.

②In the case where a trust that took effect before the Effective Date of the Trust Act (for a trust created by will, including one for which the will was made before the Effective Date of the Trust Act, and excluding a trust prescribed in the proviso to Article 12, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 (hereinafter referred to as the "Former Corporation Tax Act" up to Article 48 of the Supplementary Provisions); hereinafter referred to as an "old trust" in this paragraph) comes to fall under the category of a trust subject to corporate taxation on or after the Effective Date of the Trust Act, the provisions of Article 4-7, item (ix) of the Corporation Tax Act as amended by the provisions of Article 2 apply by deeming the old trust to be a trust for which a beneficiary, etc. prescribed in that item is deemed to hold the assets and liabilities included in its trust property.

The provisions of Article 47, paragraph (1) of the New Corporation Tax Act apply to a contract pertaining to a lease transaction prescribed in that paragraph that a corporation concludes on or after April 1, 2008, and with regard to a contract pertaining to the leasing of substituted assets prescribed in Article 47, paragraph (1) of the Former Corporation Tax Act that a corporation concluded before that date, the provisions then in force continue to govern.

①The provisions of Article 57, paragraph (10) of the New Corporation Tax Act apply to the amount of unappropriated loss listed in item (i) of that paragraph in the case where a corporation effects, on or after May 1, 2007, a qualified merger, etc. prescribed in that item with itself as the acquiring corporation, etc. prescribed in that item, and to the net operating loss listed in item (ii) of that paragraph in the case where a corporation effects, on or after that date, a qualified merger or qualified company split prescribed in that item with itself as the acquiring corporation or succeeding corporation in a company split.

②The provisions of Article 58, paragraph (5) of the New Corporation Tax Act apply to the amount of unappropriated loss caused by a disaster prescribed in that paragraph in the case where a corporation effects, on or after May 1, 2007, a qualified merger, etc. prescribed in that paragraph with itself as the acquiring corporation, etc. prescribed in that paragraph.

In the case where a corporation concluded a contract for the transfer of commodities for short-term trading prescribed in Article 61, paragraph (1) of the New Corporation Tax Act in a business year prior to the business year of the amendment (meaning the first business year starting on or after the Effective Date; hereinafter the same applies in this Article) and delivers those commodities for short-term trading in a business year on or after the business year of the amendment, the capital gain or capital loss prescribed in that paragraph pertaining to the transfer is included in the amount of gross profit or the amount of deductible expenses for the business year containing the date of the delivery, notwithstanding the provisions of that paragraph; provided, however, that this does not apply to a transfer for which the corporation concluded the contract in a business year prior to the business year of the amendment and included the amount equivalent to the capital gain or capital loss prescribed in that paragraph pertaining to the transfer in the amount of gross profit or the amount of deductible expenses for the business year containing the date on which the contract was concluded.

①The provisions of Article 61-2, paragraphs (2), (4) and (9) of the New Corporation Tax Act apply in the case where a merger, company split by split-off or share exchange is effected on or after May 1, 2007, and with regard to the case where a merger, company split by split-off or share exchange was effected before that date, the provisions then in force continue to govern.

②The provisions of Article 61-2, paragraphs (5) and (6) of the New Corporation Tax Act apply to a qualified merger or qualified company split by split-off that a corporation effects on or after May 1, 2007, and with regard to a qualified merger or qualified company split by split-off that a corporation effected before that date, the provisions then in force continue to govern.

③The provisions of Article 61-2, paragraphs (7), (8) and (10) of the New Corporation Tax Act apply to a qualified merger, qualified company split or qualified share exchange that a corporation effects on or after May 1, 2007.

④The provisions of Article 61-2, paragraph (22) of the New Corporation Tax Act apply to a merger, company split or share exchange that a corporation effects on or after May 1, 2007.

The provisions of Article 61-11, paragraph (1), item (iv) and Article 61-12, paragraph (1), item (ii) of the New Corporation Tax Act apply to the corporations listed in those provisions pertaining to a qualified share exchange carried out on or after May 1, 2007, and with regard to the corporations listed in Article 61-11, paragraph (1), item (iv) and Article 61-12, paragraph (1), item (ii) of the Former Corporation Tax Act pertaining to a qualified share exchange carried out before that date, the provisions then in force continue to govern.

The provisions of Article 62-2, paragraphs (2) and (3) of the New Corporation Tax Act apply to a qualified merger or qualified company split by split-off that a corporation effects on or after May 1, 2007, and with regard to a qualified merger or qualified company split by split-off that a corporation effected before that date, the provisions then in force continue to govern.

The provisions of Article 62-7, paragraph (7) of the New Corporation Tax Act apply in the case where a corporation effects a specific qualified merger, etc. prescribed in that paragraph on or after May 1, 2007.

The provisions of Article 62-8, paragraphs (4), (6) and (7) of the New Corporation Tax Act apply to a merger that a corporation effects on or after the Effective Date with itself as the acquired corporation, and with regard to a merger that a corporation effected before the Effective Date with itself as the acquired corporation, the provisions then in force continue to govern.

The provisions of Article 63 of the New Corporation Tax Act apply to the amount of proceeds and the amount of expenses pertaining to the sales, etc. of assets prescribed in paragraph (1) of that Article that fall under the category of long-term installment sales, etc. prescribed in paragraph (6) of that Article pertaining to a contract concluded on or after April 1, 2008, and to the amount of proceeds and the amount of expenses pertaining to a lease transfer prescribed in paragraph (2) of that Article pertaining to a contract concluded on or after that date, and with regard to the amount of proceeds and the amount of expenses pertaining to the sales, etc. of assets prescribed in Article 63, paragraph (1) of the Former Corporation Tax Act that fall under the category of long-term installment sales, etc. prescribed in paragraph (5) of that Article pertaining to a contract concluded before that date, the provisions then in force continue to govern.

The provisions of Article 64-2 of the New Corporation Tax Act apply to a lease transaction prescribed in paragraph (3) of that Article pertaining to a contract concluded on or after April 1, 2008.

The provisions of Article 81-9-2, paragraphs (2) through (4) of the New Corporation Tax Act apply to the amount of unappropriated loss prescribed in Article 81-9, paragraph (2), item (iii), (a) of the New Corporation Tax Act or the individually attributed amount of consolidated operating loss listed in (b) of that item of an acquired corporation, etc. prescribed in Article 81-9-2, paragraph (2), item (i) of the New Corporation Tax Act in the case where a consolidated parent corporation that is a consolidated corporation showing a loss, etc. prescribed in paragraph (2) of that Article effects a qualified merger, etc. prescribed in item (i) of that paragraph on or after the Effective Date, to the net operating loss prescribed in Article 81-9, paragraph (2), item (i) of the New Corporation Tax Act, or the net operating loss prescribed in item (ii), (a) of that paragraph or the individually attributed amount of consolidated operating loss listed in (b) of that item, that arose in each business year or each consolidated business year prior to the applicable business year or applicable consolidated business year prescribed in Article 81-9-2, paragraph (3) of the New Corporation Tax Act of a consolidated parent corporation or consolidated subsidiary corporation prescribed in that paragraph in the case where the first day of the consolidated parent corporation's first business year prescribed in that paragraph of the consolidated parent corporation or consolidated subsidiary corporation falls on or after the Effective Date, and to the amount of unappropriated loss prescribed in Article 81-9, paragraph (2), item (iii), (a) of the New Corporation Tax Act or the individually attributed amount of consolidated operating loss listed in (b) of that item that arose in each business year or each consolidated business year prior to the applicable business year or applicable consolidated business year prescribed in Article 81-9-2, paragraph (4) of the New Corporation Tax Act of an uncontrolled corporation prescribed in that paragraph in the case where a consolidated parent corporation prescribed in that paragraph effects a qualified merger, etc. prescribed in that paragraph on or after the Effective Date, and with regard to the net operating loss or individually attributed amount of consolidated operating loss specified in Article 81-9, paragraph (2), item (iii) of the Former Corporation Tax Act of an acquired corporation, etc. prescribed in Article 81-9-2, paragraph (2), item (i) of the Former Corporation Tax Act in the case where a consolidated parent corporation that is a consolidated corporation showing a loss, etc. prescribed in paragraph (2) of that Article effected a qualified merger, etc. prescribed in item (i) of that paragraph before the Effective Date, the net operating loss or individually attributed amount of consolidated operating loss specified in Article 81-9, paragraph (2), item (i) or (ii) of the Former Corporation Tax Act that arose in each business year or each consolidated business year prior to the applicable business year or applicable consolidated business year prescribed in Article 81-9-2, paragraph (3) of the Former Corporation Tax Act of a consolidated parent corporation or consolidated subsidiary corporation prescribed in that paragraph in the case where the first day of the consolidated parent corporation's first business year prescribed in that paragraph of the consolidated parent corporation or consolidated subsidiary corporation fell before the Effective Date, and the net operating loss or individually attributed amount of consolidated operating loss specified in Article 81-9, paragraph (2), item (iii) of the Former Corporation Tax Act that arose in each business year or each consolidated business year prior to the applicable business year or applicable consolidated business year prescribed in Article 81-9-2, paragraph (4) of the Former Corporation Tax Act of an uncontrolled corporation prescribed in that paragraph in the case where a consolidated parent corporation prescribed in that paragraph effected a qualified merger, etc. prescribed in that paragraph before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 81-13 of the New Corporation Tax Act apply to corporation tax on consolidated income for a consolidated business year of a consolidated corporation set forth in paragraph (1) of that Article for which the consolidated parent corporation's business year prescribed in Article 15-2, paragraph (1) of the New Corporation Tax Act starts on or after the Effective Date, and with regard to corporation tax on consolidated income for a consolidated business year of a consolidated corporation set forth in Article 81-13, paragraph (1) of the Former Corporation Tax Act for which the consolidated parent corporation's business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act started before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 132-2 of the New Corporation Tax Act apply to acts or calculations that a corporation performs on or after May 1, 2007, and with regard to acts or calculations that a corporation performed before that date, the provisions then in force continue to govern.

The provisions of Article 138, item (v) of the Corporation Tax Act as amended by the provisions of Article 2 apply to dividends, etc. prescribed in that item that are to be received on or after the Effective Date of the Trust Act, and with regard to dividends, etc. prescribed in Article 138, item (v) of the Former Corporation Tax Act that are to be received before the Effective Date of the Trust Act, the provisions then in force continue to govern.

With regard to the application of penal provisions to acts committed before this Act (or, for the provisions set forth in the items of Article 1 of the Supplementary Provisions, those provisions; the same applies hereinafter in this Article) comes into effect and to acts committed after this Act comes into effect in the cases where the provisions then in force continue to govern pursuant to the provisions of these Supplementary Provisions, the provisions then in force continue to govern.

Beyond what is provided for in these Supplementary Provisions, transitional measures necessary in connection with the enforcement of this Act are specified by Cabinet Order.